We submitted our responses to the planning application, which stretched to 26 pages on 18 August. The council have refused our request to upload it to the planning website, so that the objections to the scheme can be seen. You can either download it as a pdf here : Link to download of our planning response ( pdf )

1. Introduction

1.1. Cambridgeshire County Council are applying to themselves for planning permission for a £4.5m bridge crossing, flood defence works, a haul road and compounds to be constructed on Fen Ditton Meadows, an area of highly sensitive and beautiful floodplain.

1.2. Ditton Meadows, the iconic setting for Fen Ditton village and described as the Granchester of East Cambridge, will be significantly impacted by this major application.

1.3. The justification for the proposal and overriding these environmental impacts appears largely based on congestion for cyclists at nearby Green Dragon Bridge. This appears to be of marginal economic benefits and number of cars removed from road is less than 200 per day.

1.4. The 2-hectare application area includes 4 County Wildlife Sites and a Local Nature Reserve;two rivers Cam and Coldhams Brook (aka Cherry Hinton Brook or River Stour ); two Conservation Areas, multiple Listed Buildings and is within the Green Belt. It is therefore a highly sensitive location.

1.5. The scheme is shown in the diagram attached to the end of this document.

1.6. We can find no record for screening for EIA as having been undertaken, and believe that this would be appropriate in this case in combination with the Chisholm Trail, of which it is an integral part.

1.7. The application only considers the effects of the operational Bridge – 10% of footprint – and not the effects of construction, of the haul road, of the compound area, of changes in hydrology, of light pollution and of excavations for flood defences. This is an issue for biodiversity, heritage, landscape, rights of way and flood defence.

1.8. The present application is neither coherent nor does it supply sufficient information for an informed judgement to be made. Whilst councillors may attach differing weights to the value of a new cycle bridge versus the impacts from its construction, the effects on this highly sensitive floodplain environment should be subject to proper scrutiny and due process.

2. Planning overview

2.1. Deficiencies in application

2.1.1. No adequate screening for EIA appears to have been undertaken for this project, either alone or in-combination with the Chisholm Trail.

2.1.2. We believe the application as submitted to be deficient for the purposes of determination in that :

the application form as submitted contains factual errors and an unclear description of the project[1];

it is supported by insufficient information e.g. no heritage assessment; no traffic assessment; effects on Fen Ditton Conservation Area

that the design and consultation process failed to consider alternatives;

that the consultation process has not been transparent or inclusive and is misrepresented in the application;

that no cost-benefit analysis has been made;

that the usage figures as presented are misleading;

that no in-combination or cumulative effects with the Chisholm Trail have been considered

2.2.Deficiencies in consultation

2.2.1. Serious concerns have been expressed as to why £4.5m use of tax payers’ money plus £8m for Chisholm Trail has been prioritised over other city projects, and about the transparency of the previous consultation process. This is the subject of a petition to Cambridge City Council.

2.2.2. The portrayal of the consultation in the application selectively omits key details.

2.2.3. Over 600 objections were raised by concerned residents at the consultation stage, as a result of poor consultation. This fact is not mentioned within the consultation.

2.2.4. The results of consultation meetings with Fen Ditton Parish Council are not mentioned within the application.

2.2.6. Despite being verified on 25 June and the Cambridge Cycling Campaign being notified on 11 July, the general public were only officially notified of the application on 28 July.

2.2.7. During the period of public comment, the Cambridgeshire County Council website frequently crashed and did not allow comments to be made. The consultation was timed to include the peak of the summer holidays, and requests for extensions were refused by the planners.

2.2.8. Pre-application meeting notes with County Council planners were not made available to the public. Responses by the public to the planning application were not published on the council website.

2.2.9.We do not believe that the consultation for this project has been carried out in a suitable or transparent fashion, either prior to or during the application.

2.3. Objections to application

2.3.1. We wish to object to the planning application as submitted as submitted is contrary to Cambridge City Council plan policies and the National Planning Policy Frameworks, in particular but not exclusively that :

it has an adverse effect on protected and priority species e.g. otters, bats, water voles, reptiles ;

it has an adverse effect on protected sites and priority habitats i.e. County Wildlife Sites, City Wildlife Sites, floodplain grazing marsh;

it constitutes inappropriate development in a Green Belt;

it has an adverse effect on the landscape, including the setting of the Riverside and Stourbridge Common Conservation Area;

it constitutes inappropriate development in a floodplain and increases flood risk;

the design quality of the bridge and scheme is poor;

it involves the development on contaminated land near Ditton Walk;

it will have adverse impacts on heritage and quiet enjoyment of the area e.g. the Bumps course and rowing

2.3.2. The planning application has demonstrable significant adverse impacts and is contrary to NPPF or local plan policies with respect to the following issues :

Heritage;

Biodiversity;

Landscape and Green Belt;

Rights of way;

Transport;

Traffic ;

Contamination;

Flood risk;

for none of which an adequate solution has been demonstrated.

2.3.3. The benefits of the planning application would therefore need to outweigh these impacts, but the Transport benefits appear marginal.

2.3.4. The justification for planning approval appears to be largely based on reducing congestion on Green Dragon Bridge. The Demand Assessment, based upon its own figures, primarily consists of a switch from other routes, and the modal shift is small ( <200 users[2]). The Sequential Test for Flood Risk appears to have been incorrectly applied, in that no alternatives to building a new bridge were examined. There is no cost-benefit or other economic figures presented to demonstrate any overwhelming economic benefit. The social impacts and equality issues of the scheme are not considered.

2.3.5. As such the planning application does not demonstrate overwhelming public benefit, does not accord with being sustainable development and the planning application should be rejected in its’ present form.

2.3.6. We will now deal with each of these subjects in turn.

3. Heritage

3.1. Overview

3.1.1. The Government has set out its planning policies for the historic environment and our heritage assets in the NPPF. It was published in March 2012 and replaced PPS5. The government published its Planning Practice Guidance in March 2014 and keeps it updated as appropriate.

3.1.2. Both the NPPF and Planning Practice Guidance and the Practice Guide are material considerations in relevant planning applications and in relation to all listed building consents and planning permission for relevant demolition in a conservation area.

3.1.3. Paragraphs 126 to 141 contain the heritage specific policies in the NPPF, but other policies expressly apply to the historic environment also.

3.1.4. The objective of the policies is to maintain and manage change to heritage assets in a way that sustains and, where appropriate, enhances its significance. That significance is the value of a heritage asset to this and future generation because of its heritage interest, which may be archaeological, architectural, artistic or historic. This significance may derive not only from its physical presence but also from its setting.

3.1.5. Harm to conservation areas and listed buildings can be caused in any number of ways including through development within their boundary or within their setting, with or without demolition being involved. Their conservation should always be given ‘great weight’ and any harm can only be justified if the application clearly and convincingly shows that the harm will be outweighed by public benefits.

3.1.6. In order to make a sound decision a planning authority needs to understand from the applicant the significance of any heritage asset affected (paragraph 128). This may require some investigative work, but the information to be supplied with the application should be proportionate to the asset’s importance and the potential impact.

3.2. Appraisal of application

3.2.1. The application is not accompanied by a Heritage Statement. There is no assessment by an archaeologist or walkover of the site. The only consideration of “Heritage” is within the planning statement, which appears to have been carried out by a non-specialist.

3.2.2. The application is :

Within the Stourbridge Common and Ditton Meadows Conservation Area;

Within the setting of the Fen Ditton Conservation Area;

Within the setting of a number of listed buildings, e.g. St Mary Church at Fen Ditton ( Grade II*) and the Leper Chapel ( Grade I );

Within the setting of city heritage assets e.g. pillbox and the Maltings

Within an area of previously undeveloped floodplain where undiscovered archaeology is likely.

3.2.3. There is no assessment of either the significance of the heritage assets or the impact of the proposals in order to assist in determining the decision, which immediately contravenes paragraph 128 of NPPF.

3.2.4. We believe there is the prime facia potential to cause significant damage to heritage assets present.

3.3. Objection

3.3.1. We request that the applicant submits a proper heritage assessment for consideration

3.3.2. We object on the lack of heritage information supplied and consequent deficiency of the application, which contravenes paragraph 128 of NPPF.

3.3.3. We believe that there are obvious significant impacts on Heritage, including the setting of Conservation Areas and Listed Buildings, and the application is contrary to NPPF and local planning policies, and should be rejected.

4. Biodiversity

4.1. Overview

4.1.1. The 2 hectare application area includes :

4 County or City Wildlife Sites : Ditton Meadows County Wildlife Site; Old Mildenhall Railway Line City Wildlife Site; Stourbridge Common City Wildlife Site; River Cam

Stourbridge Common Local Nature Reserve

Coldhams Brook (aka Cherry Hinton Brook or River Stour )

protected species, such as reptiles, bats, water voles and otters;

priority habitats, such as floodplain grassland and chalk streams;

brownfield areas, scrub and many mature trees.

4.1.2. The application is in a highly-sensitive functional floodplain environment. It directly connects to Abbey Meadows County Wildlife Site to the south. The site is part of an important network of wildlife habitat that links :

East-west along the Cam valley, reaching westwards to Stourbridge Common and eastwards to meadows around Fen Ditton

North-south along the course of the Coldham’s Brook, which becomes the Cherry Hinton Brook higher and includes much of Abbey, Romsey and Cherry Hinton in its catchment. This tributary links the undeveloped areas of Abbey Lakes, Coldham’s Common, Barnwell LNRs and Coldhams Lane Lakes to the Cam valley.

4.2. Planning context

4.2.1. Para 109 of the NPPF states that : “ The planning system should contribute to and enhance the natural and local environment by:

minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;

preventing both new and existing development from contributing to or being put at unacceptable risk from, or being adversely affected by unacceptable levels of soil, air, water or noise pollution or land instability; and

4.2.2. Para 109 of the NPPF states that : “To minimise impacts on biodiversity and geodiversity, planning policies should:

plan for biodiversity at a landscape-scale across local authority boundaries;

identify and map components of the local ecological networks, including the hierarchy of international, national and locally designated sites of importance for biodiversity, wildlife corridors and stepping stones that connect them and areas identified by local partnerships for habitat restoration or creation;

promote the preservation, restoration and re-creation of priority habitats, ecological networks and the protection and recovery of priority species populations, linked to national and local targets, and identify suitable indicators for monitoring biodiversity in the plan;…..”

4.2.3. Para 118 states that : “When determining planning applications, local planning authorities should aim to conserve and enhance biodiversity by applying the following principles:

if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused;

opportunities to incorporate biodiversity in and around developments should be encouraged;

planning permission should be refused for development resulting in the loss or deterioration of irreplaceable habitats, including ancient woodland and the loss of aged or veteran trees found outside ancient woodland, unless the need for, and benefits of, the development in that location clearly outweigh the loss”

4.2.4. City Policy states under Policy 4/6 Protection of Sites of Local Nature Conservation Importance that development will not be permitted if “it will have an adverse impact on a Local Nature Reserve (LNR), a County Wildlife Site (CWS), or a City Wildlife Site (CiWS) unless it can be clearly demonstrated that there are reasons for the proposal which outweigh the need to safeguard the substantive nature conservation value of the site.” Where development is permitted, proposals should include measures to minimise harm, to secure suitable mitigation and/or compensatory measures, and where possible enhance the nature conservation value of the site affected through habitat creation and management.”

4.2.5. City Policy 4/7 Species Protection states that “Sites, including buildings, which support species protected by English or European Law, will be safeguarded from development proposals which would destroy or adversely affect them. Planning permission for the development of such sites will not normally be granted unless there is an overriding need for the development. If development is allowed, planning conditions and/or obligations will be imposed to:

facilitate the survival of individual members of the species;

reduce disturbance to a minimum; and

provide adequate alternative habitats to sustain at least the current levels of population of the species.”

4.2.6. City Policy 4/8 Local Biodiversity Action Plans states” rare or vulnerable habitats identified in Cambridgeshire’s Local Biodiversity Action Plans, and habitats which support species identified in those Plans, will be protected from harmful development. Such development will not be permitted unless the need for it outweighs the harmful effects. Where such development is permitted, proposals should include measures to minimise harm and mitigate the harmful impacts”.

4.2.7. We have serious concerns as to

the insufficient extent of the study area for biodiversity and

the suitability and standard of the studies undertaken.

the impacts on habitats

the impacts on species

4.2.8. The first two versions of the application form omit the presence on-site of protected species, habitats and sites.

4.3. Study area

4.3.1. Only the direct footprint of the works seems to be studied and assessed. This is based on reference to Section 1.1 and 1.2 of the Ecological Assessment:

1.1 Terms of reference : “Other works within the Application Site, including haul routes and site compounds which were not available at the time of the ecological impact assessment and may be subject to change. Further assessment of these areas may be required prior to works starting on site”

1.2 The Ecological Impact Assessment …..is approximately 0.35ha.”

4.3.2. Within Table 3-2 the areas surveyed total only 0.26 hectares

4.3.3. We note that whereas the total footprint of the application is close to 2 hectares the area assessed is only 0.35 hectares. The discrepancy is shown in Diagram F1.

4.3.4. This lack of assessment is repeated in the text. On para 1.1 it is stated that the “Scheme is adjacent to the River Cam to the east of Cambridge City, as identified on the DRAFT Proposed Scheme/General Arrangement in Error!Reference soutce not found ( hereafter referred to as the Ecological Impact assessment Area”

4.3.5. It also states that “Other works within the Application Site include haul routes and site compounds which were not available at the time of the ecological impact assessment and may be subject to change”

4.3.6. Under Section 1.3 para 3, it repeats that “The proposed site compounds and haul routes shown in Appendix A will result in further loss of land within the Barnwell Junction Disused Railway cWS and Ditton Meadows CWS, but that these losses are outside the Ecological Impact Assessment Area.

4.3.7. Within the final paragraph of Section 2.2.3, it is stated that “The final extent of the Scheme is not known at this stage. …..This assessment is therefore based only upon the works shown on Proposed Scheme/General Arrangement in Appendix A ( Drawing No 5040126/BR/GA/001 ).” This drawing is prominently marked “Draft” and would indicate that the assessment was not made on final scheme. We note that no such document is included within the planning application.

4.3.8. There is a second diagram HW 5040126/HW/LP/001 is included in Appendix 1, but does not appear to be the one assessed by the ecologist.

4.3.9. The ecological assessment therefore considers only the effects of the operational Bridge – 13% of footprint – and not the effects of construction, of the haul road, of the compound area, of changes in hydrology, of light pollution and of excavating flood defence pits. We are unclear if this device has been used to avoid EIA, as there is a significant discrepancy.

4.3.10.The conclusion would be that only the direct footprint of the bridge has been surveyed and that the scheme as submitted has not been fully assessed for its ecological impacts.

4.4. Suitability and standard of the studies undertaken

CIIEM Code of Conduct

4.4.1. Claim of compliance with “Best Practice” when unfounded are in contravention of the CIIEM Code of Conduct[3] and BS40202.

Compliance with Guidelines for Ecological Impact Assessment in the United Kingdom

4.4.2. We note that the report claims compliance with current good practice i.e. CIIEM ( 2006)[4]

4.4.3. However insufficient supporting information is supplied on surveys for birds, bats, reptiles, water voles, otters, vegetation and habitats to allow proper assessment, contrary to both CIIEM ( 2006 ) and BS4020. Furthermore the report does not consider cumulative or in-combination effects of the site development as per CIIEM ( 2006) e.g. with the Chisholm Trail, which is significant with respect to such matters as ecological connectivity and catchment level effects.

4.4.4.We also note that the effects on designated sites ( see Section 3.4 ) are excluded from further assessment and that no assessment is made for the aquatic environment.

Bat Surveys for Professional Ecologists: Good Practice Guidelines

4.4.5.The report also claims compliance with BCT ( 2016 ) guidance[5], when survey effort is only compliant partially with BCT ( 2012). In the more recent guidance, recommendations for survey effort in areas of high suitability for bats have increased significantly. The survey does not comply with these.

Confusion over Coldhams Brook

4.4.6. There appears to be some confusion within the text about where Coldhams Brook is. The water body described in the text as “Coldhams Brook” appears to be the boundary ditch between Ditton Meadows and the railway line. Table 3-2 describes it as standing water.

4.4.7. This confusion is of concern as it is unclear whether the surveyors have also surveyed Coldham’s Brook itself and also whether the hydrological assessment can be correct if this is identified as a stream.

NVC survey and Phase 1 survey

4.4.8. We are unclear of which areas were covered by this survey, since the habitat types within the NVC survey do not correspond to the Phase 1 map e.g. no ruderal or ditch vegetation is described. Furthermore areas identified as “Marshy grassland” by the NVC are identified as “Semi-improved grassland” by the Phase 1.

Conclusion

4.4.9. The conclusion would be that the report as presented is internally inconsistent but also claims compliance with Good Practice which are demonstrably not correct.

4.4.10. We will raise additional issues by topic below with respect to suitability and standard of the studies undertaken.

4.5. Habitats and designated sites

General

4.5.1. Appendix D1 has an inaccurate map in that marshy grassland is shown as semi-improved grassland and areas of ruderals and scrub are not present.

4.5.1. River Cam

4.5.1.1. There is no survey data given on the River Cam to indicate the structure and ecology of the river and its banks and bed or aquatic biodiversity.

4.5.1.2. Based on our own observations, the southern river fringes appear to have a shallowly sloping gravel margin with emergent, floating and aquatic vegetation. Emergent vegetation includes Glyceria maxima, Iris pseudoacorus, Sparganium erectum and the tall purple flowers of Lythrum salicaria, mixed frequently with Lycopus europeaus. Floating vegetation includes Glyceria declinata , Nuphar lutea and submerged macrophytes. The banks are steep and actively eroding into bays and small banks, but otherwise this area of the river bank appears largely natural in character. The northern bank is piled and trained. Water quality is good.

4.5.1.3. It is not therefore unsurprising therefore that the River Cam is a County Wildlife Site of regional significance.

4.5.1.4. Piling is likely to destroy the river’s natural morphology and alter flow regimes with an adverse effect on the integrity of the CWS. It is inevitable that with high levels of usage that the underpass will become lit, affecting the ecology of the Cam.

4.5.2. Fen Ditton Meadows

4.5.2.1. This is described within the text section 3.2 and in Table 3-2 as “Species poor semi-improved grassland identified as the habitat Coastal and Floodplain Grazing Marsh priority habitat”

4.5.2.3.We note the ditch that is listed as “Coldhams Brook” was not accessed for the NVC survey in June 2015. The ditch itself as visible from the adjacent land has tall fen vegetation with Glyceria maxima and Carex riparia dominant. Some stretches are overgrown with bramble. It is most likely to correspond to S6 Carex riparia swamp or S7 Glyceria maxima, but is an integral feature of the meadows and Section 41 habitat.

4.5.2.4. Ditton Meadows is a City Wildlife Site containing marshy grassland which corresponds to Coastal and Floodplain Grazing Marsh, which is a national[6] and county BAP[7] habitat. The report claims that such habitats are widespread locally, however given the surrounding area is urban such habitats are clearly localised ( hence designation as a City Wildlife Site ).

4.5.2.5. The project directly impacts the meadows by destroying habitat, altering the hydrology and urbanising the area. The proposed mitigation by creation of grassland on the ramps is not comparable as this is not floodplain grassland; furthermore the landscaping mitigation specifies these areas as tree planting.

4.5.2.6. The project will have a significant effect on the site’s integrity.

4.5.3. Coldhams Brook

4.5.3.1. There appears to be some confusion within the text about where Coldhams Brook is. Our understanding is that it passes under the railway line via a culvert to the south of the site, and exits into the Cam about 40m west of the railway bridge.

4.5.3.2. Within this reach the brook is relatively natural, naturally meandering and includes riffles, pools. The stream holds species such as Potamogeton pectinatis and Scrophularia umbrosa.

4.5.3.3. It should be noted that Coldhams Brook is also the major drainage for much of East Cambridge. Coldham’s Brook is a chalk stream and therefore a priority habitat, both on a county [8]basis and nationally. There is no data presented on whether this brook contains spined loach Cobitis taenia another UK BAP species.

4.5.3.4. The brook is the only remaining substantially natural chalk stream within the city boundary and one of the few of such high quality within Cambridgeshire, and is therefore rare and irreplaceable within the local context.

4.5.3.5. The report contains no information on the brook where it comes into contact with construction at the south of the site. The project directly threatens the brook by separating it from the surrounding flood plain by the haul road, altering its hydrology and urbanising its bankside vegetation. Furthermore longer term this section is likely to become lit and heavily disturbed by the Chisholm Trail, creating additional impacts.

4.5.3.6. We would conclude that the project will have a significant effect on the site’s integrity .

4.5.4. Old Mildenhall Railway Line

4.5.4.1. This is an area of dense scrub and mature trees at the south of the site, which is proposed for complete removal to create the haul road and flood compensation. The areas which are City Wildlife Site will be completely destroyed.

4.5.4.2. This significant impact is not mentioned in the report. We would conclude that the project will have a significant effect on the site’s integrity .

4.6. Species

4.6.1. Reptiles

4.6.1.1. No reptile surveys have been carried out at the site, either north or south of the river. This is contrary to good practice guidance such as CIIEM ( 2006). Species such as slow worm are localised in Cambridgeshire and may be present on brownfield sites such as the former depot and the Barnwell Junction Disused Railway Line.

4.6.1.2. There were recent losses of reptile colonies from the nearby new Chesterton Station development, which do not appear to have received compensatory habitat.

4.6.1.3. No mitigation or compensatory habitat for reptiles is proposed.

4.6.1.4. We would conclude that the project will have a significant effect on the species if present at the site, but also on reptiles within the wider network .

Birds

4.6.1.5. We note that the surveys were conducted late in the season, and may have missed early singing species e.g. chiff chaff, Sylvia warblers and Cetti’s warbler. As noted above site development will involve considerable loss of scrub habitats with a potentially deleterious effect on these species.

4.6.1.6. We note that the location of nesting barn owls seen during the bird surveys is not identified.

4.6.1.7.We note that no reference is made to wintering birds e.g. snipe on the site, despite this being a key feature for floodplain grassland biodiversity.

4.6.1.8.We conclude that the effect on birds has not been fully considered.

4.6.2. Bats

4.6.2.1. Under Section 2.2.3, it is noted that “The methodology used to carry out the bat surveys was followed from the Bat Surveys for Professional Ecologists: Good Practice Guidelines ( 2nd edition ) but since then the 3rd edition has been published ( BCT 2015). The methodology has not changed between the 2nd and 3rd edition.”

4.6.2.2. We note that the methodology has changed substantially between these two documents, in particular survey effort. [BCT note on required effort ]

4.6.2.3. We note that static surveys were not undertaken “due to concerns over the security of the Application Site” and that “the risk of damage to or theft of equipment was considered to outweigh any potential benefit of static detector surveys“. We find it relatively surprising that given the site was subject to traffic assessment DIRECTLY on the footpaths, that static equipment could not be installed at the site e.g. behind the railway line fence. The decision seems therefore largely to be a cost-saving exercise rather than one based on ecology. This is especially significant given the low level of effort by active methods.

4.6.2.4. Under section 2.2.3, it also states that “No potential roosting features were identified on or adjacent to the Ecological Impact Assessment Area“. We find this surprising and note that within Atkins (2009) it states that “At TN 9 is a pill box within a small triangle of maturing woodland. Pillboxes can be very useful at bat roosts and this appeared to have slots in only one side, and therefore should not be draughty and could be used by bats.” Even therefore within the consultants’ own report, there is a pill box identified with bat roost potential. We note additional trees with significant defects within the arboriculture report, which would form potential roosts.

4.6.2.5. Under section 2.2.3, it also states that “two activity surveys carried out manually on the site provided information regarding the species of bats using the site and the areas of foraging and commuting SUFFICIENT to inform the mitigation for the scheme”.

4.6.2.6. Given that the survey data appears to omit obvious roosting features, does not comply with survey effort for either manual or static surveys, and only encompasses 13% of the study area, we feel that it is highly unlikely that it is sufficient to “inform mitigation for the scheme”.

4.6.2.7. The project involves extensive clearance at the south of the site to build the haul road. This will impact on the old Mildenhall Railway line, but also mature trees with bat potential.

4.6.2.8. We would conclude that the development would involve significant loss of high-quality commuting and foraging habitat for bats, including linkages to roosts further south near Barnwell Junction. We would also conclude that roost sites could be potentially lost or damaged as a result of the development, but this has not been properly assessed.

4.6.3. Otters

4.6.3.1. Table 3-4 indicates “No [otter] records within 1km. No evidence of otter was identified during the protected species survey”. This is based on a survey conducted on 20 July 2015 there was no evidence of otter activity.

4.6.3.2. However on 6 June 2016, otter spraints were found at OS grid reference TL47275998 by the Cambridgeshire mammal recorder. This location is on the short length of Coldham’s Brook going NNW towards the Cam and about 200m from the proposed bridge crossing point. We note that there are additional records for Stourbridge Common and along the Cam available online.

4.6.3.3. We also note that within Atkins repot for the Chisholm Trail ( Atkins 2009 ), it is stated that “The section of the River Cam which crosses the study area had cleared grassed banks with little shelter for otters to use as sheltering habitat. However, otters are known to use the river for feeding and commuting, so potential effects on this species should be considered when the preferred route has been selected.” This description contradicts the conditions on site at the present, but notes the need to consider the effects.

4.6.3.4. The ecological report by Atkins ( 2016) fails to assess the effects on this species. Given that the species is an Annex II European protected species, protected under the Habitats Regulations, this is a significant omission.

4.6.3.5. The project will destroy or degrade otter habitat, both directly and by alterations to hydrology and the tranquillity of the area, which will create additional disturbance. The use of lighting, both now and in the future has the potential to further degrade the suitability for otters. Furthermore the bridge and access routes will fragment habitat both along the Cam and along Coldham’s Brook will prevent access upstream in to the catchment.

4.6.3.6. We would conclude that there is a significant effect on this BAP, UK protected and European Annex II species.

4.6.4. Water voles

4.6.4.1. On 6 June 2016 mink scat were found at several places on the same length of Coldham’s Brook and where it crosses Ditton Meadows. This indicates that the local water vole population is already under threat from predation, and clearly it will be impacted further by building the bridge.

4.6.4.2. The report does not assess the size of the population or its significance nor its connectivity or the vulnerability of the population.

4.6.4.3. Water voles have localised populations within Cambridge and significant populations are present along Coldhams Brook and within Ditton Meadows. The project will destroy or degrade habitat and construction effects from the haul road may potentially completely destroy the colony by increased mortality. Furthermore the bridge, ramps and access routes will fragment habitat both along the Cam and along Coldham’s Brook, and planting plans for landscaping will degrade any replacement ditches.

4.6.4.4. We would conclude there is the potential for localised extinction and for wider impacts on populations within the catchment from fragmentation.

4.6.5. Invasive species

4.6.5.1. We note that there are very obvious specimens of the invasive species Himalayan balsam on the site by the edge of the railway. We find it peculiar that these have been missed.

4.6.5.2.We conclude that the application as presented is deficient.

4.6.6. Species and habitats of principal importance

4.6.6.1. There is no list within the report of Section 41 : Species and habitats of principal importance, but the following are noted :

Chalk rivers and stream

Floodplain and coastal grazing marsh

4.6.6.2. Species present known to be or potentially present :

Water vole,

Otter,

Common Lizard,

Slow worm,

Grass snake,

Soprano pipistrelle,

Brown long-eared bat

Spined loach Cobitis taenia

4.6.6.3. Para 109 of the NPPF states that ( as per the NERC Duty ): “The planning system should contribute to and enhance the natural and local environment by:

minimising impacts on biodiversity and providing net gains in biodiversity where possible, contributing to the Government’s commitment to halt the overall decline in biodiversity, including by establishing coherent ecological networks that are more resilient to current and future pressures;”

4.6.6.4. Similarly it would be contrary to 4/8 Local Biodiversity Action Plans.

4.6.6.5. The impact on these biodiversity features and any net losses need to be taken into account, but at present the development is likely to have an adverse impact on protection and enhancement of these biodiversity features.

4.6.6.6. We conclude that the application is deficient in not considering them or demonstrating “no net loss”.

4.7.Likely ecological effects

4.7.1.Exact effects are unclear due to insufficient information. The major effects include :

Extensive damage and fragmentation to the Cam and Coldhams Brook floodplains and physical loss of wildlife sites;

The removal of significant areas of scrub and trees;

Loss of commuting routes and roosts for bats and wildlife along the river valley, either from direct habitat loss or light pollution;

Loss of connectivity to the Cherry Hinton catchment via Coldham’s Brook for water voles, fish and otters;

The potential for pollution events during construction, including from contaminated soil;

The degradation or loss from culverting of water vole habitat;

A net loss of floodplain grassland and wetland habitats and other Section 41 habitats;

Alterations to hydrology of floodplain grassland and functionality of the floodplains.

4.7.2.These example impacts are significant and are all contrary to both the NPPF and local plan policy.

Objections for biodiversity

4.7.3. We object on the lack of information supplied and consequent deficiency of the application.

4.7.4. We request that the applicant submits additional information for consideration, including:

A full assessment of the impacts of the development;

Additional assessments of the impacts on otters;

Additional surveys for bats;

4.7.5. We believe that there are potentially significant impacts on Biodiversity and the application is contrary to NPPF and local planning policies, and that as per para 118 of the NPPF : “if significant harm resulting from a development cannot be avoided (through locating on an alternative site with less harmful impacts), adequately mitigated, or, as a last resort, compensated for, then planning permission should be refused”

5. Landscape

5.1. Overview

5.1.1. The planning application is not complete. The actual assessments only deal with the bridge itself and not other effects such as construction routes or the Chisholm Trail.

5.1.2. The haul road borrow pits and cycleways will cause additional impacts e.g. from tree removal , that are not detailed. In particular the removal of scrub and trees screening the industrial estate on Ditton Walk will have very significant impacts, but is not identified.

5.2. Deficiencies in application

5.2.1. Lack of information

5.2.1.1. The application doesn’t identify the relationship of the location to the Stourbridge Common and Fen Ditton Meadows Conservation Area or the setting of Fen Ditton Conservation Area or the listed buildings in Fen Ditton e.g. St Marys Church or nearby e.g. the Leper Chapel. This increases the sensitivity of these receptors in both the LViA and the LCA assessments.

5.2.1.2. The full impacts of the development are not identified in particular the haul road borrow pits and cycleways (?)will cause additional impacts. The applications seems to have parts of Chisholm Trail on, but it is not clear if this is assessed.

5.2.1.3. We have noted in a separate section the lack of a Heritage Assessment for the site.

5.2.2. Deficiencies in assessment

5.2.2.1. The actual assessment only appears to deal with the bridge itself and not other effects such as construction or the Chisholm Trail.

5.2.2.2. The application doesn’t consider impacts on the setting of Fen Ditton Conservation Area or the listed buildings in Fen Ditton e.g. St Marys Church.

5.2.2.3. The haul road in particular will cause additional impacts from tree removal that are not detailed. There are also borrow pits and cycleways (?). Attached pdf is the best reference document. This seems to have parts of Chisholm Trail on.

5.2.2.4. There will be complete tree removal on the old Mildenhall Railway Line ( also a CiWS) to construct the haul road and Chisholm Trail, which is on the south side of Ditton Meadows. At the present time this treeline exposes the upper roofs of the Maltings, but masks the oil depot and the industrial units. This is not assessed in the landscape report. This will also alter the ZVi as there will be increased visibility from and to Ditton Walk and receptors like the Leper Chapel.

5.2.3. Visualisations as submitted

5.2.3.1. The diagrams as supplied are not compliant with national guidance on LVIA.

5.2.3.2. Their visualisations also suffer from a lot of “unexpected clutter” such as passing trains and rowers. These should be removed as distractions, especially in nocturnal visualisations, where trains alter the perceived impacts of the bridge.

5.2.3.3. The application lacks visualisations from the following significant viewpoints :

Through the tunnel that will be formed by the two bridges in close succession, especially given the interaction of the two superstructures. This both day and night as no street lighting under the bridge is envisaged.

From the existing cycle way as they approach the bridge from the south-east

From passing trains ( this is especially sensitive due to the framed views towards Fen Ditton church from the elevated position through the bridge and the level of users )

From the long distance footpath crossing the application site in direct proximity, which is a PROW

South towards the proposed compound and haul road – here much of the screening trees along the edge of the industrial buildings are likely to be removed

5.2.3.4. The assessment as submitted is deficient until these are submitted .

That the sensitivities as assessed are incorrect

5.2.3.5. The landscape report considers neither

the Stourbridge Common and Ditton Meadows Conservation Area, which encompasses the whole site,

nor the directly adjacent Fen Ditton Conservation Area,

nor the setting of any of the listed buildings.

5.2.3.6. We suggest that the sensitivity of the both the views and character areas are underestimated and should be raised to high based on these issues.

The full effects are not considered

5.2.3.7. There will be complete tree removal on the old Mildenhall railway line ( also a CiWS) to construct the haul road and Chisholm Trail, which is on the south side of Ditton Meadows. At the present time this treeline exposes the upper roofs of the Maltings, but masks the oil depot and the industrial units. It doesn’t seem to be assessed in the landscape report.

The severity of impacts are underestimated

5.2.3.8. The severity of impacts are underestimated for the landscape character ( excluding considering Conservation Areas issues ) :

5.2.3.9. The following considers only the information submitted and not the omissions.

5.2.3.10. The matrix on “Table 2.6 Significance of effects” identifies the significance of the impacts. on p30 Table 4-3 in Landscape assessment and take as an example

5.2.3.11. “River Corridor- Commons “,is identified as ”High sensitivity” and the impact Magnitude is given as “ Opening year – Medium adverse; Year 15 – Low adverse”. This would imply from the matrix that there is a Large adverse and Moderate adverse for significance of effect according to Table 2.6. However these are listed as Moderate at start and Slight after 15 years ?

5.2.3.12. Under the Landscape Institute’s guidelines for assessing landscape effects, 15 years is defined as long-term and the “Moderate” impact would be a long-term significant impact and unacceptable.

5.3. Our assessment

5.3.1. The project will cause significant and widespread change within the landscape character of Ditton Meadows and surrounding areas by introducing an incongruous bridge and ramps, by the removal of trees along the old Mildenhall Railway line ( exposing industrial buildings to view ), as a result of construction of a haul route and borrow pits for flood defence. These effects will be significant and long-term, reducing the quality of the landscape character by urbanising it and reducing its tranquility .

5.3.2. It will also cause significant impacts on the landscape character of two Conservation Areas and cause significant impacts on the settings of listed buildings, including St Mary’s Church. It will also affect the setting of Chesterton Church, whose spire is visible from the meadow.

5.3.3. Based even on the applicant’s assessment, which assess reduced extent and sensitivity of the landscape, the application would have a significant impact.

5.3.4. The mitigation by landscape planting does not appear to be deliverable without additional impacts on the biodiversity of Ditton Meadows, and is in direct conflict to that proposed for wildlife.

5.4. Objections for landscape

5.4.1. We object on the lack of information supplied and consequent deficiency of the application.

5.4.2. We request that the applicant submits a proper landscape assessment for consideration detailing all impacts and taking into account the designations of the surrounding area and presence of listed buildings.

5.4.4. We request that apparent conflicts with mitigation for wildlife are resolved.

5.4.5. We believe that ( as identified within the applicants report ) there are significant impacts on Landscape and the application is contrary to NPPF and local planning policies.

6. Greenbelt

Overview

6.1. NPPF para 88 indicates that : “When considering any planning application, local planning authorities should ensure that substantial weight is given to any harm to the Green Belt. ‘Very special circumstances’ will not exist unless the potential harm to the Green Belt by reason of inappropriateness, and any other harm, is clearly outweighed by other considerations.”

6.2. No consideration is made in the document of the scale of impact or whether the harm to the Green Belt is outweighed by other considerations.

Objection

6.3. We wish to object to the planning application on the basis that :

No evidence is presented as to its compliance with NPPF para 88;

The development is inappropriate within a Greenbelt due to its urbanising effect.

7.Rights of way and leisure use

7.1.Overview

7.1.1. Government guidance considers that the effect of development on a public right of way is a material consideration ( Rights of Way Circular 1/09- Defra October 2009, para 7.2 ).

7.1.2. NPPF para 75 states that “Planning policies should protect and enhance public rights of way and access. Local authorities should seek opportunities to provide better facilities for users, for example by adding links to existing rights of way networks including National Trails”

7.1.3. There is a Public Footpath through the proposed development area, including a long-distance footpath, which is the Harcamlow and Fen Rivers.

7.1.4. There are designated cycle routes crossing through the application area.

7.1.5. We also note that the site is part of the course for the Bumps and used by significant numbers of rowers.

7.2.Deficiencies in application

7.2.1. No information is supplied on the effects of the development on PROW and transport, other that modelling for bridge usage.

7.2.2. The works areas extend to 2 hectares and includes haul routes and borrow pits ( to win materials for embankments ). It also intersects a footpath, which is the Harcamlow and Fen Rivers Long-distance footpath.

7.2.3. No assessment is made in the application on the impact on rowers and their use of the river.

7.2.4. We conclude that this information should be supplied so that an assessment can be made.

7.3. Impacts of works

7.3.1. The effects on the right of way, either temporary during construction or permanently,are not identified. It appears looks like the construction will interfere with or divert a footpath during construction.

7.3.2. There are also long-term impacts on the rights of way. To find this issue you need to go to Figure 2 on p37 of the Flood Risk Assessment ( doc ref 41128-195095790.pdf ) and look for Compensation Areas 1 and 2. It would appear will lower these areas to bring increase flood storage, which would reduce usability during flood events.

7.3.3. The development will alter the Bumps course and riverside paths, and will create a new obstacle from the extended walkway under the bridge. The flow patterns will also be altered by piling and construction works, and access will be restricted during construction.

7.3.4. We conclude that there will be significant potential impacts on existing rights of way and recreational use of the river by rowers, which have not been considered.

7.4. Objection

7.4.1. We object on the lack of information supplied and consequent deficiency of the application

7.4.2. We request that the applicant submits a proper assessment for consideration

7.4.3. We believe that there are potentially significant impacts on Rights-of-way and the application is contrary to NPPF and local planning policies.

8. Transport

8.1. Overview

8.1.1. The application appears to be primarily justified on transport grounds i.e. congestion for cyclists at nearby Green Dragon Bridge or reduction in car traffic.

Actual usage

8.1.2. However only about 10% use of the headline figure for the bridge would be an immediate “modal shift” i.e. instead of car, train or bus, they are cycling or walking. Most of the people are simply switching from the three other bridges nearby or going to Chesterton train station instead of Cambridge. The bridge therefore simply redistributes existing use.

8.1.3. Actual present trips switched from car to walking or cycling is 381 ONE WAY TRIPS (304 cycle and 77 pedestrians)[9] equivalent to 190 individuals based on return journey, equivalent to £11,842.11 per user. This figure includes some switches from bus, so may be lower.

Reliability of modelling

8.1.4. We note that the approach used via Webtag does not justify modelling for pedestrians changing routes based on their “quality”. It is therefore are unclear if the results for pedestrains are reliable. The modelled figures were also increased from those observed as a “correction factor” for apparent low usage, which will probably lead to further overestimation of use of the facility.

8.1.5. The traffic figures were for May. We believe that during periods of bad weather and winter months usage will be lower than modelled.

8.1.6. We note that all of the approaches to the bridge will be unlit ( from upto 1km) and without overlooking houses or boats. By contrast both Fen Ditton and the Riverside Bridge have street lit approaches and overlooking houses or boats.

8.1.7. We believe that the locations are too isolated for many users to prefer to use with confidence.

Economics

8.1.8. Based on 123 900 people in Cambridge, and the new Abbey-Chesterton Bridge costing at least £4.5 million, it will cost each Cambridge citizen £36.32 to fund building the bridge.

8.1.9. The Chisholm Trail costs a further £8 million. With these together only 3150 people will use the bridge[10].

8.1.10. The cost of the bridge alone – £4.5m over 3150 users – equates to £1429 per user. With additional costs of the Chisholm Trail, the cost per user rises to £3,867.37 or £193.37 per user per year assuming 20 years lifespan. [11] There is therefore a huge net transfer to cycle users of the bridge to the detriment of others in Cambridge. If we were to benchmark it in monetary value, the £12.5m for the project represents another 70-80 units of housing for Cambridge – equivalent to permanent local homes for close to 250 people avoiding the necessity for travel by car.

8.1.11. Based on a Cost Benefit Ratio of 30:1 as indicated by council officers, the benefit of each switch from motorist to cycling or walking would be £354,330.71. We feel this is unlikely.

8.1.12. If the project is to proceed, costs should be reduced. Friends of Coldhams Common propose the Cheap as Chips option – a modification of the Chisholm Trail to use existing infrastructure as far as possible and focusing on signposting, resurfacing existing paths and fixing potholes in roads. This would increase attractiveness to cyclists, but also reduce environmental impacts ( since the “Cheap as Chips” option already exists ).

Poor transport connections

8.1.13. We also note that the connection of the bridge remains via an unsuitably narrow and unlit southern walkway, which is less than 2m wide. The site is in a remote location and will not be used late at night by those concerned about security. The lack of lighting is an impediment to partially sighted users of the facility, but provision of lighting would create additional environmental impacts. We note that the width of the walkway is too narrow to allow disabled users or those with prams through safetly. The walkway is presently already unsafe at levels of use of a fraction of that predicted.

8.1.14. On the north side of the bridge, we note that no connection is made to allow residents of Fen Road east of the railway to use the bridge or the underpass. No connection to east of the line on Fen Road means that the residents, school children and workers there cannot use the facility or safely avoid the level crossing. Given the ethnicity of many of these residents, we find this decision to be of concern.

8.1.15.We believe that the scheme has poor transport connections and is contrary to City policies. We find the lack of a connection to Fen Road east of the railway line to be of significant concern.

Encouraging London commuting

8.1.16. With direct access from Abbey to Chesterton Station will become a base for London commuters, who will then price out the local community and increase travel distances for local workers. The purpose of the station is to encourage commuters coming into Cambridge rather than cause the converse and push the working community further out.

8.1.17. There is no assessment of the social impact of the bridge in terms of transport. We conclude that the social impact of this should be assessed in that there may be unforeseen consequences in an increase in road traffic from the development.

8.2. Objection on transport grounds

8.2.1. The project has significant environmental impacts. In order to demonstrate overriding public interest would need to be demonstrated, which is not.

We object on the basis that no cost-benefit analysis has been carried out.

We object that no social impact or equality study has been conducted for it;

We believe there should be transparency as to why there is no connection to Fen Road east of the railway line;

We believe that by encouraging London commuting the scheme may increase road traffic by increasing houses prices in Abbey and excluding local key workers;

We object on the basis that no alternative solutions have been properly examined e.g. “do nothing”

We also believe that no evidence is presented as to overriding public interest, and that the application should therefore be rejected.

9. Traffic

9.1. Overview

9.1.1. The application does not deal with traffic impacts from the development, in particular for construction e.g. import and export of materials for the haul road and flood defence excavations.

9.1.2.This includes excavation of possibly contaminated ground [ not clear as not covered by Contamination Assessment ] and the construction traffic for lorries will probably use Wadloes Road, a quiet residential road [ not clear as contains no Traffic Assessment ].

9.1.3.We conclude that the impacts of traffic are potentially severe and should be considered before the application is determined.

9.2. Objection on traffic

9.2.1. We object in that :

The traffic movements to and from and within the site for construction are potentially significant, based on the location within an urban area;

We believe that a Traffic Assessment is required as part of the application and should not be conditioned.

10. Contamination

10.1. Overview

10.1.1. We note that the study area on the applicant’s maps within the land contamination desk study :

10.1.2.In particular the applicant proposes removal of parts of the old Mildenhall Railway line for flood compensation, including an area near the oil depot on Ditton Walk. Local residents believe that oil deliveries would formerly been made along this railway line in the 1950s and 60s, and this would also impede any historical contamination movement from the depot.

10.1.3. This application includes excavation of possibly contaminated ground along the old MIldenhall Railway line, which is clear not covered by Contamination Assessment.

10.2. Objection on Contamination

10.2.1. We wish to raise an objection based on two points :

That the contamination issues in these areas have not been fully considered, since they are not within the scope of the submitted contamination report;

That the method for disposal of any excavated contaminated materials is not identified and could be within the floodplain e.g. used for haul roads or bridge embankments.

11. Flood risk

11.1. Overview

11.1.1. The Sequential Test for development in a flood plain requires that alternative locations and solutions are demonstrated before development is considered within a floodplain.

11.1.2. We note that the Sequential Test appears to have been incorrectly applied for development in Zone 3, and in fact only locations in very close proximity were looked at i.e. the presumption was always of a bridge in this location as being necessary. Other alternatives such as “Do nothing” or upgrades to Green Dragon bridge were not considered, but there is no demonstration that they would not deliver the project objectives. No evidence for alternatives being looked at have been explored.

11.1.3. The Exception Test must be followed subsequent to the Sequential Test : “If following application of the Sequential Test it is not possible consistent with wider sustainability objectives for the development to be located in zones with a lower probability the Exception Test can be applied.”

11.1.4. There is however as noted previously no clear evidence as to the importance of the scheme ( se Transport ). The Exception Test is not therefore met as the scheme is not of overriding public importance or essential as proposed. It is noted that p2 of the accompanying Technical Note for the Flood Risk Assessment indicates that other locations were dismissed before consultation in July 2014, but also that “the alternative alignments were not considered suitable in line with the wider objectives of Cambridgeshire County Council therefore the exception test has been applied.”

11.1.5. Furthermore we note that much of Ditton Meadows is flooded annually, so flood return periods are likely to be underestimated.

11.1.6. Ground water flow is very common along the high ground along the edge of the meadows in early spring, and has not been included within the hydrological modelling.

11.1.7. We also note that fluvial flooding only seems to have been considered for the Cam and the connectivity of Coldhams Brook has been ignored. There have been recent flood events on Barnwell Road caused by the brook, which is also the main drain for East Cambridge. Its flood plain includes much of Ditton Meadows, but this hydrological connection will be impeded by the haul road. Connectivity between the Cam and the floodplain via reverse flows up the ditch along the railway line will also be compromised.

11.1.8. We note ( see Contamination ) that some of the compensation areas involve contaminated ground and may impact on the hydraulics of contamination within the old oil depot. We also note within the proposed compensation areas that there is an intermediate pressure gas main; that they include sections of PROW; that they contain BAP habitats and that they contain commuting habitat and potential roosts for bats, and that it will involve the destruction of a City Wildlife Site. We do not believe that they can therefore be delivered.

11.2. Objection on Flood risk

11.2.1. We believe that the project, both during construction and in operation may increase flood risk, especially in relation to Coldham’s Brook, which is the main drain for East Cambridge. We wish to object in that :

We do not believe that the Sequential Test has been correctly applied in looking at alternatives solutions and location.

We do not believe that the Exception Test has been correctly applied and was pre-determined, but also that there is no demonstration of overwhelming need for the project.

We believe that there is the potential for increased flood risk from Coldhams Brook.

We believe that the compensation areas are not properly assessed for their impacts, but also cannot be delivered and therefore there will be an adverse effect on flood risk.

The development would thus be contrary to National Planning Policy Framework and the local plan and should be rejected.

Figure showing extent of works

[1] We note that there are three versions of the application form on the council website.

[2] This switch includes switches from trains and buses to cycling and walking.